Pilli Rama Raju vs The State Of Telangana on 24 July, 2026

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    Telangana High Court

    Pilli Rama Raju vs The State Of Telangana on 24 July, 2026

       IN THE HIGH COURT FOR THE STATE OF TELANGANA
    
                           AT HYDERABAD
    
    
           THE HONOURABLE SMT. JUSTICE K. SUJANA
    
    
               CRIMINAL PETITION No.12368 of 2025
    
    
                          DATE: 24.07.2026
    
    
    BETWEEN:
    
    
    Pilli Rama Raju and others
    
    
                                 .....petitioners/accused Nos.1 to 11
    
    
                                  And
    
    
    The State of Telangana and another.
    
                                        .....Respondent/complainant
    
    
                                 ORDER
    

    This Criminal Petition is filed seeking to quash the

    proceedings against the petitioners/accused Nos.1 to 11 in

    SPONSORED

    C.C.No.34 of 2025 on the file of the learned Special Judicial

    Magistrate of First Class for Excise Cases, Hyderabad, registered

    for the offences punishable under Sections 143 and 188 read

    with 149 of IPC.

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    Crl.P.No.12368 of 2025

    2. The brief facts of the case are that on 15.11.2021, the

    petitioners, along with other BRS/TRS party leaders and

    workers, allegedly conducted a press meeting at IKP Centre,

    Arjalabavi Village, Nalgonda, without wearing face masks,

    without maintaining social distancing, and in violation of the

    COVID-19 guidelines and the Model Code of Conduct for the

    MLC Elections, 2021. Based on the complaint lodged by the

    Assistant Sub-Inspector of Police, Nalgonda Rural Police

    Station, Crime No.282 of 2021 was registered for the offences

    under Sections 143 and 188 read with 149 IPC. After

    investigation, a charge sheet was filed, which was taken on file

    as C.C.No.34 of 2025 against the petitioners.

    3. Heard Sri Sanjeeva Reddy Garlapati, learned counsel

    appearing on behalf of the petitioners, as well as Sri D. Arun

    Kumar, learned Additional Public Prosecutor appearing on

    behalf of the respondent-State. Though notice was served upon

    respondent No.2, none appeared on his behalf.

    4. Learned counsel for the petitioners submitted that the

    allegations in the charge sheet are omnibus in nature and do

    not disclose the essential ingredients of the offences alleged. He

    contended that the prosecution under Section 188 IPC is barred

    in the absence of a written complaint as mandated under
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    Crl.P.No.12368 of 2025

    Section 195 Cr.P.C., and therefore the entire proceedings are

    vitiated. He further submitted that the FIR was lodged with

    unexplained delay, the prosecution is politically motivated, and

    the continuation of criminal proceedings would amount to

    abuse of the process of law. Therefore, he prayed to quash the

    proceedings against the petitioners.

    5. Learned Additional Public Prosecutor contends that the

    material on record shows that the petitioners and others

    conducted a public meeting without adhering to the COVID-19

    protocol and in violation of the Model Code of Conduct during

    the MLC Elections, 2021. The investigation, including witness

    statements and video footage, prima facie establishes the

    involvement of the petitioners in the alleged offences. He

    submitted that the allegations require appreciation of evidence

    during trial and, therefore, at the stage of quashing, the

    proceedings should not be interfered with and are liable to be

    continued.

    6. In the light of the submissions made by both the learned

    counsel and a perusal of the material available on record, it

    appears that the petitioners were charged for the offences

    punishable under Sections 143 and 188 read with 149 of the

    Indian Penal Code, 1860. It is specifically contended by the
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    Crl.P.No.12368 of 2025

    learned counsel for the petitioners that as there is a bar under

    Section 195 (1) (a) of Cr.P.C., whereunder, a written complaint

    has to be filed by the public servant/authorized officer, the

    Police has to follow the same, but the same is not followed in the

    present case. Further, at this stage, it is imperative to note the

    relevant Sections, which are as follows:

    7. Section 188 of the I.P.C reads as follows:

    Section 188: Disobedience to order duly promulgated
    by public servant.

    Whoever, knowing that, by an order promulgated by a
    public servant lawfully empowered to promulgate such
    order, he is directed to abstain from a certain act, or to
    take certain order with certain property in his possession
    or under his management, disobeys such direction,
    shall, if such disobedience causes or tends to cause
    obstruction, annoyance or injury, or risk of obstruction,
    annoyance or injury, to any persons lawfully employed,
    be punished with simple imprisonment for a term which
    may extend to one month or with fine which may extend
    to two hundred rupees, or with both; and if such
    disobedience causes or tends to cause danger to human
    life, health or safety, or causes or tends to cause a riot or
    affray, shall be punished with imprisonment of either
    description for a term which may extend to six months,
    or with fine which may extend to one thousand rupees,
    or with both.

    Explanation: It is not necessary that the offender should
    intend to produce harm, or contemplate his disobedience
    as likely to produce harm. It is sufficient that he knows
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    Crl.P.No.12368 of 2025

    of the order which he disobeys, and that his
    disobedience produces, or is likely to produce, harm.

    Illustration: An order is promulgated by a public
    servant lawfully empowered to promulgate such order,
    directing that a religious procession shall not pass down
    a certain street. A knowingly disobeys the order, and
    thereby causes danger of riot. A has committed the
    offence defined in this section”.

    8. Section 195(i) (a) of Cr.P.C., reads as under:-

    “(i) (a) of any offence punishable under Sections
    172
    to 188 (both inclusive) of the Indian Penal Code
    (45 of 1860), or

    (ii) of any abetment of, or attempt to commit, such
    offence, or

    (iii) of any criminal conspiracy to commit such
    offence, except on the complaint in writing of the
    public servant concerned or of some other public
    servant to whom he is administratively subordinate;”

    9. Reverting to the facts of the case on hand, a perusal of

    Section 188 of IPC makes clear that to take cognizance there

    should be a written complaint and such complaint should be

    filed either by the officer issuing such promulgation order or the

    officer above his rank. Further, Section 2 (d) of Cr.P.C., defines

    complaint as allegations made orally or in writing to the

    Magistrate with a view to the Magistrate taking action on such

    complaint, the Magistrate can take cognizance under Section
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    Crl.P.No.12368 of 2025

    190 (1)(a) of Cr.P.C.. Thereafter, the procedure prescribed

    under Section 200 of Cr.P.C has to be followed. Therefore, the

    first information report, charge sheet and the order taking

    cognizance on such charge sheet are without jurisdiction.

    10. Further, it is significant to note the judgement of the

    Honourable Supreme Court in State of Karnataka v.

    Hermareddy 1, wherein in paragraph No.8, it is held as under:

    “8. We agree with the view expressed by the
    learned Judge and hold that in cases where in the
    course of the same transaction an offence for which no
    complaint by a Court is necessary under Section 196
    (1)(b)
    of the Code of Criminal Procedure and an offence
    for which a complaint of a Court is necessary under
    that sub-section, are committed, it is not possible to
    split up and hold that the prosecution of the accused
    for the offences not mentioned in Section 196 (1)(b) of
    the Code of Criminal Procedure should be upheld”

    (Emphasis supplied)

    11. In the instant case, a perusal of the charge sheet discloses

    that the petitioners are sought to be prosecuted for the offence

    punishable under Section 188 of IPC including other penal

    provisions i.e., 143 of IPC. As per the judgment of the Hon’ble

    Supreme Court in Hermareddy (supra) it is clear that if the

    offences formed part of the same transaction of the offences

    1
    AIR 1981 SC 1417
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    Crl.P.No.12368 of 2025

    contemplated under Section 191 of Cr.P.C., it is not possible to

    split up and hold the prosecution of accused for the other

    offences. In view of the above, the FIR culminating in taking

    cognizance of the aforesaid offences stands vitiated. Hence,

    continuation of criminal proceedings against the petitioners is

    nothing but abuse of process of law.

    12. Accordingly, the criminal petition is allowed and the

    proceedings against the petitioners in C.C.No.34 of 2025 on the

    file of the learned Special Judicial Magistrate of First Class for

    Excise Cases, Hyderabad, are hereby quashed.

    Miscellaneous applications, if any pending, shall also

    stand closed.

    _______________
    K.SUJANA, J
    Date: 24.07.2026
    SAI
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    Crl.P.No.12368 of 2025

    THE HONOURABLE SMT JUSTICE K. SUJANA

    CRIMINAL PETITION No.12368 of 2025

    Date: 24.07.2026
    SAI



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